Rental Car Firm Not Responsible for Driver With Ignition Lock Restriction on License

A car rental company in Connecticut is under no obligation to confirm whether a customer’s driver’s license is subject to any restrictions; rather it is only required to inspect the physical license card to confirm that it is facially valid and unexpired.

A Connecticut Appellate Court has upheld a lower court’s grant of summary judgment for EAN Holdings, LLC, also known as Enterprise Rental Car, in a personal injury action alleging the firm was negligent in renting a vehicle to a driver who was subject to an ignition lock restriction.

On the day of the rental, the customer struck the plaintiff pedestrian while driving the EAN vehicle. Police officers conducted a field sobriety test, which the driver failed, and subsequently arrested him for operating a motor vehicle while under the influence of alcohol or drugs.

The complaint alleged negligent entrustment by EAN in renting a vehicle to a driver who was only supposed to drive vehicles with ignition interlock devices. The rental car had no such device. Ignition interlock devices measure the blood alcohol content of an operator and disallow the operation of the vehicle if the blood alcohol content exceeds a certain limit.

In addition to checking that the license was facially valid and not expired, the EAN employee observed that the customer ”did not demonstrate any signs of mental or physical impairment, or any other unfitness to operate a motor vehicle.” At the time, the employee was unaware that the renter was prohibited from operating a vehicle that did not have an ignition interlock device installed.

In his appeal, the plaintiff claimed that the lower court improperly concluded that EAN did not have a duty to use an online database to determine whether the customer’s license was subject to restrictions before renting him a vehicle.

But the appeals court found that the trial court properly determined that the defendant did not have a duty under the state law governing the renting of motor vehicles to use an online database to confirm whether the license was subject to any restrictions. The court affirmed that according to the plain language and legislative history of the statute, the rental firm was required only to inspect the physical driver’s license card to confirm that it was facially valid and unexpired. The appellate court ruled that the trial court properly granted EAN’s motion for summary judgment.

The court noted that, under the circumstances of this case, EAN did not have an affirmative common-law duty to use an online database since there were no readily apparent facts that might provide a reason to suspect that the renter had any limitation on his ability to drive. Thus, no genuine issues of material fact existed and EAN was entitled to judgment as a matter of law on the negligent entrustment claim.

Topics Auto Personal Auto